E-Prescribing in the Medicare Program on Orlando Medical News

E-Prescribing in the Medicare Program

By: LESLIE WITKIN

Bonus Potential but Ultimate Penalty

Electronic prescribing was enacted as part of the Medicare Improvements for Patients & Providers Act of 2008 (MIPPA) passed by Congress July 15, 2008.

E-Prescribing in the legislation provides for a bonus for compliance initially, but eventually a penalty if you are not "successfully" prescribing.

Bonus for "successful" e-prescribing:

2009 and 2010 – 2 percent each year of all covered allowed Part B amounts.
2011 and 2012 – 1 percent
2013 – 0.5 percent

Penalties for not e-prescribing at all or not "successfully" e-prescribing:

2012 – 1 percent - your Medicare allowed amounts would be 99% of the fee schedule amount. ***
2013 – 1.5% - your Medicare allowed amounts would be 98.5% of the fee schedule amount.
2014 and beyond – 2 percent - your Medicare allowed amounts would be 98% of the fee schedule amount.

*** (The fee reductions starting in 2012 will be based on analysis of your claims data from prior years. The first year for data review will not be before 2010)

What is "Successful" e-Prescribing?

E-Prescribing is defined as entering a prescription for a medication into an automated data entry system that generates a prescription electronically, instead of handwriting the prescription on paper. You must have a "qualified" e-prescribing system.

A "Qualified System" must:

Generate a medication list.
Select medications, transmit prescriptions electronically and conduct safety checks* as listed below:
Provide information on formulary or tiered formulary medications, patient eligibility and authorization requirements received electronically from the patient's drug plan.
Provide information on lower cost alternatives.

* Safety checks include: automated prompts that offer information on the drug being prescribed, potential inappropriate dose or route of administration of the drug, drug-drug interactions, allergy concerns, and warnings/cautions.

How do you report E-Prescribing in order to qualify for the bonus?

Reporting is accomplished through submission of your claims. Measure #125 from PQRI (Physician Quality Reporting Initiative) is the e-Prescribing measure for claims based reporting purposes. For the e-prescribe bonus potential this measure will be removed from PQRI and used exclusively for e-prescribe analysis.

The measure is intended to be reported for all eligible Medicare patients. If you render and bill for one of the following codes (called denominator codes), then you must also include a "numerator" code in your claim (referenced below) in order to report the e-prescribing measure.

Listed "Denominator" Codes:
90801, 90802, 90804, 90805, 90806, 90807, 90808, 90809, 92002, 92004, 92012, 92014, 96150, 96151, 96152, 99201, 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99241, 99242, 99243, 99244, 99245, G0101, G0108, G0109.

"Numerator" codes are currently "G" codes. The current "G" codes are as follows:

G8443 – the prescriptions generated during the patient encounter were generated using a qualified system.
G8445 – you have a qualified system but no prescriptions were generated during the patient visit.
G8446 – you have a qualified system, but some or all of the prescriptions during the encounter were handwritten or phoned in due to one of the following: required by state law (such as narcotics), patient request ( such as patient going away for winter), or your system is currently inoperable.

In order to qualify for bonus OR not to be penalized:

You must report the measure on at least 50% of eligible patients (unlike the 80% required for PQRI).
The CPT codes that make up the denominator codes must account for at least 10 percent of the provider's total allowed charges for Medicare Part B covered services.

MIPPA does allow "at the discretion" of the Secretary of Health and Human Services to change the requirement for successful reporting based on the number of Part D prescriptions.

If this happens in the future, the Part D data would be used in lieu of your having to report through the claims based system.

E Prescribing Systems

The Center for Medicare Medicaid Services (CMS) does not endorse any product but suggests you view the Web site for SureScripts to see if your current system has and/or is certified to perform the required functions.

SureScripts does not offer e-prescribe systems. They allow systems to connect to the Pharmacy Health Information Exchange System. The connection is at no charge.

For information go to:
http://www.surescripts.com/get-connected.aspx?ptype=physician

Your expenses for e-prescribing are incurred through your vendor or a stand alone e-prescribe vendor usually at a per provider cost for the system and other relevant system products. You do not have to have an electronic medical record (EMR) in order to perform e-prescribing.

Several organizations are supporting the following website to review your current status and possible needs, solutions for e-prescribe:

Physicians First, Inc. documents are designed to provide reliable and authoritative information, and every reasonable effort has been made to insure the accuracy of information. The company assumes no legal responsibility for the use or misuse of the contents of this document. Leslie Witkin, President, Physicians First Inc., Orlando, Florida - www.physiciansfirst.com.